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Representation to extend the due date of filing of Audit reports under Income Tax Act, 1961, from 30th September, 2022 to 31st October, 2022.

Please Read: CBDT extends due date for filing various Income Tax Audit reports


Dated: September 19,2022


1. Smt. Nirmala Sitharaman Ji,
The Honorable Union Finance Minister,
Ministry of Finance, Govt of India,
North Block, New Delhi – 110001.

2. Shri Tarun Bajaj Ji,
The Honorable Revenue Secretary,
Ministry of Finance, Govt. of India,
North Block, New Delhi – 110001.

3. Shri Nitin Gupta Ji,
The Honorable Chairman,
Central Board of Direct Taxes,
Ministry of Finance, Govt. of India,
North Block, New Delhi – 110001.

Subject: Representation to extend the due date of filing of Audit reports under Income Tax Act, 1961, from 30th Sept., 2022 to 31st Oct., 2022.

Honorable Ma’am and Sir’s,

Our Organization, All India Federation of Tax Practitioners (‘AIFTP’), is one of the largest professional bodies of tax practitioners comprising of Tax Professionals, Advocates & Chartered Accountants.

As your honour is aware now this is the fag end of the due date being 30th   Sept., 2022 for filing of audit reports by audit taxpayers.

Owing to various reasons, we request your honours that the due date for furnishing of the audit reports under various provisions of the Income Tax Act (‘the Act’) may kindly be extended from 3oth Sept., 2022 to 31st Oct., 2022.

Some of the reasons, owing to which, we request that the due date may kindly be extended are as under:

1. This year clause 30(c) and clause 44 of tax audit report in form 3CD has been made compulsory which is consuming lot of time in preparation of 3CD audit reports :-

Clause 44 of the 3CD audit report contains 7 columns to be filled up regarding expenditure towards goods and services from registered and unregistered entities. Column 5 of the said clause requires to furnish, “total payment to registered entities”. There is need to issue clarification by CBDT that whether “payment” under this column means to include payable also or only the actual payment during the year, further it also needs to be clarified by CBDT that the Payment under this column refers to include payment relating to purchases or expenditure incurred during the current year or any earlier year also or any advance payment for goods or services also. Further column 2 of clause 44 needs to mention total amount of expenditure incurred during the year, whether this includes Non-GST supplies also e.g. Salaries are also to be included here or not, as this needs to be clarified by CBDT. The compilation of these information’s for clause 44 may be for the purpose which shall not be served if  desired information  which is nowadays already available with the GST department on its portal  and if  it is synchronized with income tax portal by way of 26Q through 206C(1H) and 194Q etc may fulfill the purpose  But  compilation of information for clause 44 is not correctly possible whereas the tax auditor has to report correctness of data and information provided in 3CD as well as in clause 44 of 3CD, it seems that not even a single 3CD in India can provide correct data being furnished in clause 44 not because of ignorance or so but because of non-clarity of information required under these clause in absence of any proper guideline issued by CBDT.

2. Other clauses of 3CD:- information required to be furnished in clause 16(d) is also not clear in absence of proper guideline because during the AY 2021-22 many of the taxpayers had furnished information in clause 16(d) which resulted in double tax demand on them and still they are facing problems and even having to go to file appealsagainst these.

3. Clause 12 of 3CD also needs clarity :- because the said clause requires to furnish information relating to profit and gains relating to business covered U/s 44AD and 44AF and furthermore the 3CD utility provided on income tax portal also has mentioned section 44ADA which is not there in the notified 3CD tax audit format. CBDT is requested to clarify that here in clause 12 reference of Section 44AD and 44ADA and 44AF has become redundant/not required, because 44AF has become obsolete since long and 44AD as was desired has become redundant since long, because nowadays if any person is subjected to tax audit then he cannot opt for44AD or 44ADA along with tax audit therefore this will result in incorrect reporting in absence of proper guideline.

4. Clause 27a of 3CD requires information relating to CENVAT whereas utility provided by income tax portal has suo-moto asked for details of ITC (Input Tax Credit) even if not corresponding amendment in notified form 3CD, therefore taxpayers are in dilemma whether to replace CENVAT with ITC or to ignore this clause in absence of suitable modification in notified 3CD.

5. This year there are so many changes in the provisions relating to charitable and religious trusts and institutions etc. which also requires a lot of man hours to compile and present the information in audited financial statements of such entities and their audit reports.

6. Further the audit needs attest function by Chartered Accountants and much time has elapsed in waiting for clarity from CBDT in various such clauses of 3CD etc. now very less time has left only 10 days are left so this will be very less and so it is requested that the due date for audit reports may kindly be extended by one month.

Thus, in the said circumstances, it is most humbly Prayed, that the due date of furnishing audit reports may kindly be extended from 30th Sept., 2022 to 31st Oct., 2022 to avoid any genuine hardship to the taxpayers.

Furthermore, we as tax professionals, ensure that taxpayers and their auditors correctly file their income tax returns and duly discharge their liability.

Thus, in view of the above, we request your honor to kindly extend the due date of filing of audit reports from 30th Sept., 2022 to 31st Oct., 2022.

We trust your honors will accede to our above request.

Thanking you,

Yours faithfully,


Adv. D.K. Gandhi Adv. Arvind Shukla CA. Jamuna Shukla
National President



Direct Tax Committee, A.I.F.T.P.

Secretary General



Mob: 9810216801


Mob: 9415201059


Mob: 9450361366

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  2. Rajkumar iyer says:

    If the site is not working and the comman man has completed his work but cannot file it due the working of the website one cannot penalise the commman man for that. It is natural the due date has to be extended without fail

  3. azhar says:

    server is not working sitting from 7 pm for one file . please extend the date till 31.10.2022 . Already taxes paid there is no loss of revenue to govt. please extend the date humble request

  4. DINESH BHARTI says:

    please please please extend the tax audit date to 31st October as still we are busy with half yearly physical stocks and it’s really important we got delayed because of new expansions

  5. SUDAMA SHARMA says:

    the date should be extended atleast till 31.10.2022. many of the companies and firms getting difficulties comply with tax audit.

    so requesting the competent authority to extend the date till 31.10.2022

  6. Venkatesh V says:

    Dear Sir/Madam,
    We request your good selves to extend the company return filing at least by 15 days since September 30th being half yearly closing & lot of companies are busy concentrating on reaching their half yearly sales targets as we are.
    Please consider our humble request.


    Its my humble request from u mam to extend the due date by 31st oct because most of bussinessmen is involved in there marking of durga puja festival If the date is not extended It will give a huge impact on our economy and this is not good for our country and the citizens of india.
    For this I shall be highly obliged to you
    your’s faithful

  8. Nathuram Kadam says:

    I most humbly Prayed, that the due date of furnishing audit reports may kindly be extended from 30th Sept., 2022 to 31st Oct., 2022 to avoid any genuine hardship to the taxpayers.

    Thanks and regards
    N Kadam

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